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Caroline Ramsey-Hamilton

How long does it take for OSHA to develop standards – like for Workplace Violence?

Why OSHA standards take so long to develop

The Government Accountability office reports to Congress on items of interest to Congress and their constituents.  One area that was recently examined was how long it takes OSHA to update standards, or develop new standards.  Here’s a look at the results:

By:         David LaHoda  April 30th, 2012

A report by the U.S. Government Accountability Office (GAO) on why OSHA standards take, on average, more than seven years to complete found that “increased procedural requirements, shifting priorities, and a rigorous standard of judicial review” contributed to the lengthy time frame.

In responding the GAO report, Randy Rabinowitz, OMB Watch’s director of regulatory policy said: “In the years since its creation, OSHA’s charge to protect workers from harm has been undermined by Kafkaesque demands for additional reviews of existing rules mandated by new statutes and executive orders,” according to The Hill. While OSHA’s internal inability to remain focused on priorities and regulatory follow-through was the counter argument presented by the U.S. Chamber of Commerce.

“While some of the changes, such as improving coordination with other agencies to leverage expertise, are within OSHA’s authority, others call for significant procedural changes that would require amending existing laws,” according tot he GAO report.

The GAO report recommended that that OSHA and NIOSH improve collaboration on researching occupational hazards. In that way OSHA could better “leverage NIOSH expertise in determining the needs for new standards and developing them.”

To access the entire 55-page report, go to: http://www.gao.gov/products/GAO-12-330



April is Workplace Violence Awareness Month

The American Association of Workplace Violence Prevention (www.aawvp.org) has designated April 2012 as official Workplace Violence Awareness Month!

You can celebrate in your office by suggesting ways to reduce workplace violence in your own environment.  At AAWVP, they stress that workplace violence also happens to you, not just at work, but at the late-night grocery store or convenience store, in the hospital where you’re visiting your father, and even in your own home.

As part of the awareness raising event, the Association has invited me to participate in a special webinars about workplace violence at 2:00 pm Eastern Time, on April 18th.

You can join us by registering at http://tinyurl.com/85e33h8



Preview of the Webinar on Workplace Violence Prevention

Companies often don’t think about preventing workplace violence until there is an incident that affects them, or a company similar to them, or geographically close.  As soon as something happens close to home, they want to get serious and do something about it right away.

Workplace violence prevention is actually a process that, like in quantum physics, when we talked about the observed particle, just putting management’s attention on the potential problem will start the prevention process.

A good place to start is with adjusting and updating your policies.  Perhaps your policy is outdated, or hasn’t been publicized in your organization.   Time to dust it off and make sure it includes these critical elements:

1.  It says:  We have a total no-weapons policy in this company.

2.  Employees are REQUIRED to report any potential, or even suspected workplace violence situations or incidents.

3.  There is an approved company form which every employee has electronically, to use
if necessary.

4.   Every employee has to attend a violence prevention training course, or active shooter drill, or both, annually.

The policy is the first step.  Next, the policy has to be approved by the management or by the Board, and then sent to every employee, along with an affirmation agreement that they sign saying they read the policy and understand it.

More tomorrow… or attend our special workplace violence webinar.  You can sign up at:

http://t.co/rKBuoDgt



My Take on Not Having Health Insurance to Encourage Health Accountability

I raised my children without healthcare insurance!!  Wow – what a great accomplishment!  Now they are both healthy grown men who take their health very seriously. They stay in shape, exercise, both go to the gym every day or at least every other day and I think that accountability for their own health came from growing up without health insurance.

Health insurance is a scam in many ways.  It has the proven result of making people not care about their own health, not being responsible for their own health because they figure, “If something bad happens, insurance will cover it”.

So they overeat, drink too much,  eating transfat donuts, fried chicken, french fries and go to the doctor when their arteries start closing up at age 50, or when they find out they are pre-diabetic, or have high blood pressure.

My independent health care started when I didn’t have health insurance through my company, but then I got it and decided never to use it! That has been a point of honor for me.

I like the idea that I have to pay for my own health maintenance.  If I HAVE TO PAY FOR IT, I get very picky about how much I have to spend, and the best way NOT to spend money on healthcare is to STAY HEALTHY!

A revolutionary thought!  But – hey, it’s worked for me my whole life. I have never been sick, except for scarlet fever when I was 7.   So go back and read some of my other posts about working out, eating fresh, whole, organic food, and doing yoga, and whether you have health insurance or not, you may find there’s a way to stay healthy!



Man Wants to Commit Suicide at Hospital to Donate his Organs!

Suicidal Man Triggers an Evacuation in Denton, Texas.

The emergency department at Texas Health Presbyterian Hospital was evacuated after an armed man threatened to shoot himself in the hospital’s parking lot, as reported in a newspaper article. The man had sent suicidal messages to his ex-wife. She contacted police, who in turn began tracking the man’s cell phone. He was found in his vehicle, which was parked in front of the hospital’s ED. Police cleared the ED while they negotiated with him for about 45 minutes. The man told police he chose the hospital because he wanted to donate his organs after he killed himsel



17-year old imposter does CPR on patient in Kissimee, FL

Security measures in place are being questioned in Kissimmee, Florida at Osceola Regional Medical Center after clerk passes as a physicians assistant!

Hospital security procedures, including staff screening practices at Osceola Regional Medical Center, are getting a second look after a 17-year-old passed himself off as a physician’s assistant and took part in several exams and procedures, including doing CPR on a patient. The Orlando Sentinel reported that hospital management is reviewing its practices to ensure a similar incident doesn’t occur. The youth was able to secure a hospital ID badge from the human resources department by claiming to need a new one because the surgical practice at which he worked had changed names. In fact, the youth was employed part time as a billing clerk at a doctor’s office. When confronted by staff, the youth said he was working undercover for the sheriff’s department, so they would be unable to check his employment records



Man Makes Meth in his Car in Hospital Parking Lot

Hospital security cameras showed that a
33-year-old man was making meth in his car in the facility’s
parking lot before the vehicle became engulfed in flames.
The man was burned over 80 percent of his body and
later died of his injuries. The car, which was in the Horizon
Medical Center lot, was captured on security video that
showed the man mixing ingredients just before there was
fireball inside the car. A sheriff’s office detective working
security at Horizon requested assistance to put out the fire.
In examining the site, he noticed canisters and other possible
drug-related items in the car and called the drug task force,
according to news accounts



Get Ready for Severe Weather!

Whether it is Spring tornados or spring-summer thunderstorms and hurricanes.  We officially enter the season of severe weather across the U.S.

A major focus at the beginning of each severe weather season, take a few minute to get ready and make sure you are prepared, and your kids are prepared, and your pets are prepared.

You can download a complete list of preparation details at www.ready.gov but here is a
short list to review:

1.  Keep enough food and water for at least two weeks.

2.  Have a family evacuation plan and practice it often, including a meeting place.

3.  Keep a ‘ready-kit’ in your car with extra food, water, change of clothes and don’t forget to include pet food, plastic bags, diapers and other essentials that could carry you for a few days.

4.  Make sure and keep large trees trimmed to decrease the chance they could fall on your house.

5.  Use the internet, like Twitter or National Weather Service, to get breaking alerts, and invest in a battery powered radio.

6.  Keep extra batteries available to keep the radio alerts going.

7.   Keep your car gassed up, instead of running out during an emergency and finding
it’s out of gas, and remember, if the power goes out, the gas pumps don’t work.

8.  Stay alert and try to keep a day ahead of the weather!



Severe Tornados and Why We Need to Stay Prepared

The damage and destruction from the path of a tornado is incredible – and only matched by the sad stories of the survivors, if they are lucky enough to survive.

If there’s one thing that social media has improved – it is the ability of an individual in an affected area to get detailed updated by the minute on a smartphone or over the internet.

The old early warning systems were set up for radio, that was in the days when everyone listened to radios.   I do listen to the radio for maybe 5 minutes a day, in the car, just long enough to put in the CD or connect my ipod.   So the Twitter accounts and iphone-smartphone apps from CNN, the National Weather Service, Weatherbug and dozens more really help to keep people informed.

I often hear news anchors lament the over-availability of information these days, but I think the more access we get to this kind of information and other kinds of info is absolutely a wonderful thing for society and for most people!

If you do live in a tornado-, hurricane- or other disaster-likely area, the Weatherbug app is one of the best because you can set it to actually chirp if severe weather threatens.

As far as risk reduction – being able to protect yourself against major weather events is one of the threats you can more easily eliminate or at least manage.

Are there mor

“Although the average number of April tornadoes steadily increased from 74 a year in the 1950s to 163 a year in the 2000s, nearly all of the increase is of the least powerful tornadoes that may touch down briefly without causing much damage. That suggests better reporting is largely responsible for the increase.

There are, on average, 1,300 tornadoes each year in the United States, which have caused an average of 65 deaths annually in recent years.

The number of tornadoes rated from EF1 to EF5 on the enhanced Fujita scale, used to measure tornado strength, has stayed relatively constant for the past half century at about 500 annually. But in that time the number of confirmed EF0 tornadoes has steadily increased to more than 800 a year from less than 100 a year, said Harold Brooks, a research meteorologist at the National Severe Storms Laboratory. ”

 

 



Use A Data-Driven Security Program to Transform Organization Security

Data-Driven Security

How to Target, Focus and Prioritize
The Security Program

  by Caroline Ramsey-Hamilton

Management has to have Metrics

Management of a security program is no different than management of cash flow, employee productiveness, profitability, or any other set of metrics that organizations use to measure how well something is being done, and how it could be improved. Historically, however, security has been run by a few unique professionals, perhaps with a military or law enforcement background and the security program has existed in a vacuum, with few ways to measure it’s effectiveness and value to the organization, except to list what hasn’t happened!

Security officers may complain that management is not listening to their complaints, including not making enough money available to implement new technology, or to fix a loophole that has the potential to create havoc in the organization. Many security conferences feature sessions with titles like “How to Sell Security to Management” and try to address this disconnect between senior management and their security programs.

Peter Drucker, the world famous management consultant, said “If you can’t measure it, you can’t manage it.”

Very recent improvements in security technology, camera technology and its integration with computer networks and information security has allowed a massive amount of data to be collected.  Everything from digital images, to incident reporting and tracking, and even internet-based reporting of technical vulnerabilities, allow management metrics to be applied to the management of the security program to target the program to be maximally effective, to focus the available dollars in the areas which would provide the most protection for the least amount of money, and to prioritize the controls that need to be improved or implemented, based on their return on investment.

Security has never been more important to the organization. Many court cases recently have been decided on the basis of whether the organization was using ‘due care’ and utilizing every ‘reasonable’ security precaution. Existence of adequate security has become very important in premises liability cases and will likely become equally important in future litigation.

Risk assessments are the foundation of a data-driven security program. Through the process of risk assessment, managers can measure the effectiveness of the organization’s total security program, including analyzing the value of the organizational assets, the threat level (based on the mission of the organization), the existing vulnerabilities, and the effectiveness of existing controls. Basing the risk assessment on the concept of data-driven security means that real numbers are used in the following areas:

1. Determining the value of the assets of the organization, including the facilities, the personnel, products, production facilities, raw materials, transportation, vehicles, information technology equipment, data and information. In additional to quantifying present day replacement value, the sensitivity of various information assets and a determination of their criticality to the main mission of the organization must be determined.

2. Analyzing the Threat Level affecting the organization, including analyzing of incident report logs which would indicate how many potential intrusions have been attempted, as well as an analysis of physical intrusion indicators, such as missing badges, any security incidents, and any indications of industrial espionage which have been reported, either at the facility under review, or at any of the organization’s other facilities. Industry data on intrusions in similar companies or analogous agencies is also very helpful in determining threat level.

Many companies now use reports which quantify threat data, including statistics on criminal activity by exact location, by zip code (such as the Uniform Crime Index) as well as many information sources of weather data, such as NOAA (U.S. National Oceanographic and Atmospheric Administration, various international associations and government agencies.

3. Identifying vulnerabilities in the organization, including surveying individuals at every level of the organization, from the receptionist to the CEO.  To ascertain the weaknesses in the way the employees comply with security, there are new electronic survey tools,( like Risk Watch®)  which measures security compliance against published standards such as FEMA 426, (How to Protect Buildings Against Terrorist Attacks). control standards.  New regulations, like Joint Commission, Behavioral Health and Workplace Violence (OSHA 3148) require such compliance-based
baseline assessment surveys.

4. Identifying potential categories of loss, which would include components like direct losses (damage/destruction), injury or death to either staff or patients/customers/vendors; theft of property or product,  theft of data/information,  and loss of an organization’s reputation. These loss categories are used to quantify the effect of threats on the organization because you can estimate the loss impact on various functions of the organization.

5. Safeguards (Controls) include all the possible controls that could protect an organization either by reducing the likely of a threat occurring, or reducing the amount of damage that the organization sustains from a threat that materializes. Controls are quantified by:

a. Life Cycle of the Control – How Long They are Good for.

b. Cost to Implement the Control to 100% in the organization

c. Indication of the percentage that the control is already implemented in the organization

By accumulating data in these 5 categories, it becomes possible to run scenarios that pair the threat and vulnerability, match it to organizational assets, analyze the loss potential, and evaluate the cost effectiveness of a variety of different controls.

Advantages of a Data-Driven Security Program

The primary advantage of a data driven security program is that it provides support for the security function within the organization by being able to illustrate directly how security not only protects the organizational assets, but also, how the security profile changes over time.

In addition, it becomes possible to benchmark the various plants and facilities against themselves, and against both domestic and international standards, including military standards for the Defense Industrial Base. For example, if a multinational company with facilities and networks around the world can analyze their security based on the principle of a data-driven security program, then they can instantly identify the areas or facilities that have problems and address them much more quickly and effectively than they could if they were depending on a fuzzy, quantitative assessment method. When an organization makes the decision to adopted a more disciplined approach to analyzing security risk, they must also use all the other typical management functions such as planning, development of a budget and incorporation of the plan into the organization’s overall planning.

After the initial baseline risk assessment, and using the input from the analysis, the organization can began to develop implementation strategies to address the vulnerabilities identified in the assessment. As each vulnerability is addressed, cost-effective mitigation strategies can be put in place.

At the same time,  the security plans and policies can be measured so that policy changes can be made, if necessary, or training and awareness programs can focus in the areas that need reinforcement with the organization.

The Security director, using his already established budget and implementation timelines for each safeguard, can then manage the improvements, using either internal staff or he can make the decision to outsource the additional controls (or their implementation).

These improvements can be tracked themselves, to establish how effective they are in their individual tasks, and also can be periodically re-assessed to see how the organization’s total security profile has improved.

The first benefits from a data driven security program emerge during this implementation phase because not only can you measure how much more effective the new security configurations are, but there is an additional value-added component of
re-acquainting the employees with the security program and increasing awareness across the organization.

To ensure continued value in the program, collection mechanisms such as automated incident response, threat reporting and vulnerability reviews must be automated. There are new security software programs that evaluate and analyze these types of data and can dramatically increase the effectiveness of a data-driven security program.

This type of data-driven security program creates a security program that becomes a baseline for management to quickly assess the security profile of the entire organization.  It makes it easier to provide a safe, and secure workplace for both management and employees, and may decrease the possibility of a workplace violence incident, theft or domestic or international terrorist attack.

This data-based concept of risk management creates a bridge between executive management and the security professionals in the organization who now have an avenue for open communication, discussion and consideration of the role of security throughout the organization.

 

About the Author

Caroline Ramsey-Hamilton is the founder of Risk Watch International, and a leading security risk assessment expert.  She was a Charter member of the National Institute of Standards and Technology’s Risk Management Model Builders Workshop from 1988 to 1995.  From 1996-1998, she served on the working group to create a Defensive Information Warfare Risk Management Model,  (DIWRM2) under the auspices of the Office of the Secretary of Defense.  She was also a member of the National Security Agency’s Risk Rating Workshop and the IBM Data Governance Working Group to create a Data Governance model for the nation’s largest banks.

She has developed specialized risk assessment programs for HIPAA, Information Security, FFIEC, GLBA, Sarbanes Oxley, and corporate security programs including working with The Clearinghouse, large investment banks, the Federal Reserve and a variety of other Federal agencies on Risk Assessment guidelines.   In addition, she is a member of the ASIS Physical Security Council, SARMA( the Security Risk Management Association) based inWashington, D.C.  Ms. Ramsey-Hamilton is certified in Homeland Security and Anti-Terrorism and recently received a lifetime achievement award from the Anti-Terrorism Accreditation Board and the Maritime Security Council.

Hamilton works around the world on critical risk issues including a new set of risk assessment guidelines for the Nuclear Regulatory Commission, a risk model for airport security and a risk model for medication error with Philadelphia Children’s Hospital.

She has completed Risk Assessments for over twenty-five U.S. government agencies including the Department of Defense, the Technical Support Working Group, and the Nuclear Regulatory Commission, and many healthcare organizations including Cleveland Clinic, HCA, Sheikh Khalifa Medical City, the University of Miami Medical Center and many more.  She has written several books and articles over twenty-five different publications.

www.caroline-hamilton.com

caroline.r.hamilton@gmail.com

 

 

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